Privacy Policy

This Privacy Policy (this “Policy”) is prepared by SynOption Pte. Ltd. (“SynOption”, “we”, “us” or “our”) and contains important information about how SynOption processes personal datain order to carry out our activities and operationsand explains how we manage personal data in compliance with the Singapore Personal Data Protection Act 2012 (No.26 of 2012)(“PDPA”) and other applicable laws of Singapore (collectively, “Applicable Law”).

This Policy applies to personal data we collect on www.synoption.com, optimus.synoption.com and other platforms(including other mobile or web-based applications operated by SynOption) provided by SynOption (collectively, the “Platform”) about:

visitors to the Platform; and
any person who registers their email, phone number and other personal data with usto avail of services that we may from time to time make accessible on the Platform (“Services”).

By accepting this Policy or by accessing or using the Platform and/or any Services, you: (a) acknowledge that you have the right, capacity and authority to accept this Policy; (b) acknowledge that you have read and understand this Policy; and (c) expressly consent to the processing of your personal data by SynOption in accordance with this Policy. If you do not agree to this Policy, do not accept it and do not access or use the Platform and/or any Services.

This Policy may be updated from time to time to ensure ongoing compliance with Applicable Law and for any other purpose we deem reasonably necessary. We encourage you to check the latest version of this Policy regularly on this page. Your continued access or use of the Platform and/or any Services constitutes your acknowledgement and acceptance of such changes.

(1) SCOPE AND INTERPRETATION OF THIS POLICY

1.1 This Policy explains:

What Personal Data Is Collected
Purposes for Processing Personal Data
Security and Retention of Personal Data
Rights Concerning Personal Data
Disclosure and Transfer of Personal Data
Sale of Business
Changes to Privacy Policy
How to Contact Us

1.2 In this Policy:

“personal data” means information which, by itself or with other information, can be used to identify an individual; and
“processing” means the carrying out of any operation or set of operations in relation to personal data, including collecting, using, disclosing, recording, holding, organising, adapting, altering, retrieving, combining, transmitting, transferring, erasing or destroying personal data.

1.3 This Policy forms an integral part of the Terms of Use for the SynOption Platform and should be read concurrently with it andour Security Policy.

1.4 Subject to Applicable Law, this Policy shall continue to apply to personal data in our possession even where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for such period of time as may be necessary to enable us to enforce our rights under any contract with you. (a)If the purpose for which the personal data was collected is no longer being served by retention of the personal data, and (b) retention is no longer necessary for legal or business purposes, we shall remove your personal data, we shall cease to retain documents containing personal data or remove the means by which the personal data can be associated with you.

1.5 This Policy does not apply to websites, applications or services that are not linked to this Policy or to those operated by third parties (including Facebook and Twitter). SynOption is not responsible for and shall have no liability whatsoever in connection with such third party’s processing of your personal data. We encourage you to review the privacy policies posted on those websites, applications and services.

(2) WHAT PERSONAL DATA IS COLLECTED?

When you access, use or register on the Platform, or avail of any Services,we may collect the following personal data from you:

a) Data collected directly from you: This may be done through the Platform, over the phone or by email, and comprises:

Your contact information, as well as your (first and last) name or full name, (billing and/or delivery) address, and email address, employer name (if applicable), date of birth, citizenship and, your phone number. We require your e-mail address and phone number so that we may contact you if we have queries or for information concerning your order or the service that we are offering you.
Other information required to be able to provide you the service that you have requested for, such as information concerning the services you have ordered or the service we are providing to you, the billing and/or delivery address, and/or financial details.
If you have created an online profile or account on the Platform, the preferences and interests stored in such profile or account.
If you refuse to provide any personal data listed herein that we identify as being required to access or use the Platform or anyServices, or other information that we may request under applicable law or forknow-your-client or onboardingchecks, you will be unable to access or use the Platform or any Services.

b) Data collected by automated means: different types of technologies may be used on the Platform in order to make them more user-friendly, effective and secure. These technologies may lead to data being collected automatically by us or by third parties on our behalf. This data does not generally, but may, contain user’s personal data.

Examples of such technologies include:

Click Stream data: Data that is transmitted by your browser to our server when you visit the Platform may include:

IP address
Unique device identifier
Mobile network information
Date and time of the visit
The referral site from which you came
The pages that you visited
General information such as the type, version, operating system of your browser.

Cookies: Cookies are text files placed on your computer to collect standard internet log information and visitor behaviour information. The information is used to track visitor use of the Platform and to compile statistical reports on your Platform activity. You can set your browser to not accept cookies and the Platform will tell you how to remove cookies from your browser. However, in a few cases, some of the Platform features may not function if you remove cookies from your browser.

Web Analytics: We obtain personal data about you when you visit us. When you visit us, we may monitor the use of the Platform using cookies and similar tracking devices. For example, we may monitor the number of times you visit the Platform, or which pages you go to. This information helps us to build a profile of our users. Some of this data will be aggregated or statistical, which means that we will not be able to identify you individually.

Retargeting Technologies: The Platform may use retargeting technologies within the internet. This would enable us to show our visitors, who are already interested in our products, advertisement from us on partner websites. We also work with other companies who use tracking technologies to serve advertisements on our behalf across the internet. These companies may collect non-personally identifiable information about your visits to the Platform and your interaction with our communications, including advertising. Retargeting technologies analyse your cookies and display advertisement based on your past surfing behaviour. We do not store any personal data about you using this technology.

Social Network: The Platform may provide you with social plug-ins from various social networks operated by third parties (such as Facebook and Twitter). If you choose to interact with a social network, your activity on the Platform will also be made available to social networks such as Facebook and Twitter. We do not control the collection or other processing of data transferred via social plug-ins.

(3) PURPOSES FOR PROCESSING PERSONAL DATA

3.1 We may collect, use, disclose and/or process your personal data for the following purposes:

to render any Services to you, including to send trade confirmations and to collect and manage our fees from our provision of any Services;
to provide you with the products and services that you have requested;
to provide you with a safe and convenient browsing experience;
to ensure that your transactions on the Platform are safe and secure by preventing, detecting,investigating and prosecuting security threats, fraud, misconduct or other unlawful or malicious activity on the Platform or in respect of any Services;
to authenticate your identity and instructions in respect of anyServices, including to conduct know-your-client or onboarding checks;
to contact you for feedback about a product or service that we offer;
to comply with legal and regulatory obligations and requirements;
for internal operational and administrative purposes, such asaccounting, risk management, compliance and record-keeping functions, staff training and quality control;
to carry out research, planning and statistical analysis;
to send you weekly newsletters, and contact you by telephone call, SMS, fax, post and emailabout SynOption products and services we think may be of interest to you, including research report offers and investment ideas,if you have expressly consented to be so contacted (even if you are registered with any ‘Do Not Call Registry’ established under Applicable Law) or if we are otherwise authorised under Applicable Law to contact you in this manner;
to send you hyperlinksfor downloadingthe mobile-based version of the Platform (when available);
if you have contacted us with any complaints, feedback, comments, suggestions, we will use, process and disclose your personal data (including your contact history) to respond to you and improve our Services;
to review the performance of our business partners, service providers, professional advisers, vendors and agents that provide services to us (including those that provide know-your-client or onboarding checks, data storage, maintenance, legal, audit, insurance and marketing services) in connection with the operation and development of the Platform and the provision of any Services;
to protect our legal rights, property or safety, or to protect third parties; and
to resolve disputes and enforce our agreements.

3.2 By submitting your email, you consent to the use of that email for the purposes set out in this Policy.

3.3. If we need to use your personal data for any other purposes, we will notify you and obtain your consent beforehand, unless we are authorised under Applicable Law to process your personal data without your consent.

(4) SECURITY AND RETENTION OF PERSONAL DATA

4.1 We are committed to maintaining the security of personal data. We have put in place appropriate security procedures and technical and organisational measures to safeguard your personal data such as encryption, SSL, use of passwords, etc as appropriate. We have introduced appropriate administrative, physical and technical measures to secure all storage and transmission of personal data by us and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis.

4.2 You should be aware, however, that no method of transmission over the internet or method of electronic storage is completely secure. While we strive to protect the security of your personal data in accordance with Applicable Law and are constantly reviewing and enhancing our information security measures, the security of any personal data cannot be guaranteed.Additional information on this subject is available in our Security Policy, which is available at https://synoption.com/home/security-policy/

4.3 We will retain your personal data at all times while your Platform account exists and we reserve the right to retain your personal data for as long as it is necessary to fulfil the purpose for which it was collected, or as required or permitted by Applicable Laws.

(5) RIGHTS CONCERNING PERSONAL DATA

5.1 Subject to exceptions under Applicable Law, you have the right toaccess your personal data in our possession or control any information about how we have used and disclosed your personal data. If you wish to have access to some or all of your personal data, please send an email to [email protected]. We may levy a small charge for this servicewhere we are authorised to do so under Applicable Law.

5.2 We take reasonable steps to ensure that any personal data we collect, disclose and use is accurate, complete and up to date. If any personal data which you have provided to SynOption changes, for example if you change your email address, name or payment details, or if you wish to cancel your registration, please let us know the correct details by sending an email to [email protected]. You may ask us, or we may ask you, to correct personal data you or we think is inaccurate, and you may also ask us to remove personal data which is inaccurate.

5.3 All requests for correction or for access to your personal data should be in writing. We will respond to your request within 30 calendar days and if there is any delay, we shall inform you of the time by which we would respond to you. We may be prevented or authorised by Applicable Law from complying with any request that you make.

5.4 The consent that you provide for our processing of your personal data will remain valid until such time that you withdraw your consent by submitting your request in writing or via email to our Data Protection Officer (see the contact details under paragraph 9 below).

5.5 Upon receipt of your written request to withdraw your consent, we may require reasonable time for your request to be processed and for us to notify you of the consequences of us acceding to the same, including any legal consequences which may affect your rights and liabilities to us. In general, we respond to your request within 30 calendar days of receiving it.

5.6 Please note that depending on the nature and scope of your request, we may not be able to continue providing our products or services to you and we shall, in such circumstances, notify you before completing the processing of your consent withdrawal request. Should you decide to cancel your withdrawal of consent, please inform our Data Protection Officer in writing (see the contact details under paragraph 9 below).

5.7 Please also note that notwithstanding the withdrawal of your consent, we reserve the right to retain your personal data for as long as is necessary for our legal or business purposes, including where there is a legal obligation imposed on us to do so.

(6) DISCLOSURE AND TRANSFER OF PERSONAL DATA

6.1 We do not sell, trade, or otherwise transfer to third partiesyour personal data. This does not include trusted third parties who assist us in operating the Platform and any Services, conducting our business, or servicing you, as long as these parties agree to keep your personal data confidentialand process your personal data only for the purposes set out in and in a manner consistent with this Policy. We may also share your personal data with other third parties if you have separately consented to such disclosure. In such case, any information which we share with such third parties shall have to be used by such third party for the purposes described when we obtained your consent.

6.2 We may also disclose your personal data when we believe release is appropriate to comply with the law, enforce Platform policies, or protect ours and others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to third parties for marketing, advertising, or other uses.

6.3 Your personal data may be transferred outside Singapore for processing by us, other group companies or our service providers for one or more of the purposes set out in this Policy. By accessing or using the Platform or any Services, you consent to the transfer to and other processing of your personal data in countries outside of Singapore, which may have different personal data protection rules than in Singapore. However, we will contractually require that the level of protection that will be applied to the transferred personal data will be at least comparable to the protection provided under each of the following: (a) the PDPA; (b) any applicable laws of the other countries to which your personal information will be transferred; and (c) this Policy (collectively, the “Transfer Regulations”). For the sake of clarity, in case any Transfer Regulation provides a greater standard of protection than another Transfer Regulation, then the greater standard of protection will have to be applied to the transferred personal data.

(7) SALE OF BUSINESS

If SynOption’s business is sold or integrated with another business, your details may be disclosed to our advisers and any prospective purchasers and their advisers and will be passed on to the new owners of the business.

(8) CHANGES TO PRIVACY POLICY

We will review thisPolicy regularly. If we change thisPolicy, we will post the changes on this page, and place notices on other pages of the Platform so that you will be notified of the personal data we collect and how we process it at all times. This Policy was last updated on29 October 2020.

(9) HOW TO CONTACT US

You may contact our Data Protection Officer if you have any enquiries or feedback regarding our personal data protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer

Email address: [email protected]

We welcome your views about the Platform and thisPolicy. If you would like to contact us with any queries or comments please send an email to [email protected].

DISCLAIMER

SynOption Pte. Ltd. is licensed by the Monetary Authority of Singapore as a Recognized Market Operator (“RMO”) to operate an organised market as defined under Part 1 of the First Schedule to Securities and Futures Act 2001. (the ‘Organised Market’).

This recognition as an RMO is restricted to the operations of the “Optimus” Platform, in exercise of the powers conferred to MAS under section 9(1)(b) of the SFA with effect from 31 December 2020. The Optimus platform is also exempt from Swap Execution Facility (“SEF”) registration requirements of the Commodity Futures Trading Commission (“CFTC”).

The “Synchro” Platform is a separate trading platform which is established and operated by SynOption Technologies Pte. Ltd. and is not a regulated platform by the MAS. Please refer here for additional disclosures: Additional Risk Disclosures for PTD.